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Keywords

plaintiffdefendantmotionsummary judgmentdiscrimination
plaintiffmotionsummary judgmentdiscriminationcivil rights

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Sullivan v. Hernandez, 215 F.Supp.2d 635, 24 NDLR P 121

Facts

The Sullivans, both African-American, applied for a rental property owned by the Carrolls after meeting with rental agent Jan Hernandez. After submitting their application, the Carrolls chose to rent the property to another applicant, Partha Bagchi, who had a stronger financial profile. The Sullivans alleged that their application was rejected due to their race and disability, as Carla Sullivan's credit history was negatively impacted by her disability.

In this action Harold and Carla Sullivan allege that they were unlawfully discriminated against on the basis of race and disability in violation of the Fair Housing Act, 42 U.S.C. § 3601, et seq. (“FHA”), and the Civil Rights Act of 1866, 42 U.S.C. § 1981, et seq. (“section 1981”) when their application for rental housing was rejected.

Issue

Did the Sullivans establish a prima facie case of housing discrimination based on race and disability, and could the landlords be held liable for disability discrimination?

Did the Sullivans establish a prima facie case of housing discrimination based on race and disability, and could the landlords be held liable for disability discrimination?

Rule

To establish a prima facie case of housing discrimination, a plaintiff must prove membership in a protected class, qualification for the rental, rejection of the application, and that the property remained available thereafter.

To establish a prima facie case of housing discrimination, a plaintiff must prove that: (1) he or she is a member of a statutorily protected class; (2) he or she applied for and was qualified to rent or purchase certain property or housing; (3) he or she was rejected; and (4) the housing or rental property remained available thereafter.

Analysis

The court found that the Sullivans met the first three elements of the prima facie case, as they were members of a protected class, applied for the property, and were rejected. The defendants disputed the final element, arguing that the property was not available after the Sullivans' application was rejected. However, the court ruled that the property was indeed available at the time the Sullivans' application was received, thus allowing the claim to proceed. The court also noted inconsistencies in the defendants' explanations for their decision, which could suggest pretext.

The court found that the Sullivans met the first three elements of the prima facie case, as they were members of a protected class, applied to rent the Carroll's property, were qualified to rent the property, and their application was rejected.

Conclusion

The court denied both parties' motions for summary judgment, allowing the case to proceed on the grounds of potential discrimination.

The court denied both parties' motions for summary judgment, allowing the case to proceed on the grounds of potential discrimination.

Who won?

Neither party prevailed as both motions for summary judgment were denied, allowing the case to continue for further examination of the claims.

Motions denied.

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